BIC - 2018 Registration document

RISKS

Vigilance Plan

2.3.4.

ORGANIZATION AND MEASURES FOR THE PREVENTION OF MAJOR EXTRA-FINANCIAL RISKS

provide the basis for the BIC Group’s Vigilance Plan are: The Code of Ethics, the BIC Group Anti-Corruption Policy, the BIC Group Code of Conduct, Health, Safety, Environment Policy (EH&S), the BIC Charter of Diversity, the Responsible Purchasing Charter. These documents are listed in part 3.1.2.4 Our Policies. Within the scope of the Law, the major risks listed below correspond to the most critical risks identified (resulting from the probability of occurrence and the significance of the potential impacts regarding the applicable risks).

The tables below refer to the pages of the Chapter 3 of the registration document which gives a detailed presentation of the issues, the policies, the initiatives, the accomplishments of the past year and the extra-financial performance of the BIC Group. The BIC Group implemented a body of documents to facilitate risk management. Those that address the topics covered by Law and

A.

Major risks arising from BIC Group activities [NFPS]

Mitigation and remediation measures/Due diligence and regular assessment processes /Results – Key extra-financial performance indicators See the eco-design process in section 3.2.1 Our products' environmental performance (pages 74 to 79). See the process of fight against climate change in section 3.3.1.3 Writing The Future, Together – #2 Acting against climate change (pages 88 to 91). See the product safety process in section 3.2.3 Product safety (pages 82 to 84). See the process of safety in the workplace in section 3.4.3 Health/Safety in the workplace (pages 97 to 99). See the measures for the respect of Human Rights in the workplace in section 3.5.1.2 Ensuring respect for human rights in the workplace (pages 109 to 111). See the anti-corruption fight process in section 3.5.1.3 Ethics and the fight against corruption (pages 111 to 112).

Major risks

Type of risks

Policy

Organization

Plastics: plastic waste and resource depletion

Environmental risk

2025 Commitment: #1 Fostering sustainable Innovation in BIC ® products

Implementation by the Categories, by the Purchasing Department, with the support of the Sustainable Development Department Implementation by the Sustainable Development Department EH&S Officer in each factory Implementation by the Product Safety Department Implementation by HR and each Category EH&S Officer in the factories

Climate change

Environmental risks 2025 Commitment: #2 Acting against climate change

Product safety and Consumer Health and Safety Health and Safety of Team members

Risks for people health and safety

BIC policies for product safety

Risks for people health and safety

2025 Commitment: #3 Committing to a safe work environment EH&S policy

Non-respect of Human Rights and Fundamental Freedoms (child labor, ILO conventions)

Risks on Human Rights and Fundamental Freedoms

Code of Ethics, HR Policy

Implementation by HR for team members

Code of Conduct

Implementation by each Factory Director

Unfair practices (Corruption)

Risks of active or passive corruption

BIC Group Code of Ethics and Anti-Corruption policies

Implementation by an Anti-Corruption Officer, the Legal Department, the Purchasing Department

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• BIC GROUP - 2018 REGISTRATION DOCUMENT •